The regulations expressly allow for a situation in which the Human Research
plans are not firm at the time of award.  NIH routinely allows an award to
be made with restrictive language stating that no expenditures may be made
for HR activities until IRB approval is received and transmitted to the
sponsor.

This example MIGHT be persuasive to the FH officer.  On the other hand, the
program officer may consider that there is too much risk that IRB would not
approve for him to OK the expenditure of the rest of the grant, which has a
large travel component.

Good Luck!

Chuck

At 02:35 PM 2/10/2004, you wrote:
>The Dept of Education's Fulbright Hays Faculty Research Abroad program
>requires that any human subjects research involved in a FRA fellowship be
>approved PRIOR TO THE START OF THE FELLOWSHIP (meaning before the faculty
>member leaves the US).     The project in question (economics/business)
>involves a survey which won't be administered  until a few weeks or more
>into the fellowship period but is still being finalized by the fellow and
>his overseas collaborators (who are the hold up).     He's scheduled to
>leave next week and our IRB can't meet before then -- in fact, he still
>doesn't have the final version.     The Fulbright Hays program officer has
>said he has to change his travel plans.      I'm hoping there are other
>solutions.
>
>I'm looking for anyone with relevant experience -- FHA fellows whose
>projects did not get IRB approval until AFTER they were abroad,
>conditional approval strategies that would allow us to submit Travel Request
>Forms (on line now) that say the project has been approved, or any other
>suggestions.
>
>We're a small liberal arts college ... IRB meets monthly, has only very
>part-time staff, handles mostly social science protocols, and has its own
>internal policy of full board review for all grant-funded research.
>
>Frances Vinal Farnsworth
>Coordinator of Sponsored Research
>Munford House
>Middlebury College
>Middlebury, VT 05753
>
>Tel:  802-443-5889
>Fax:  802-443-2081
>Email:  xxxxxx@middlebury.edu
>Web:  http://www.middlebury.edu/~grants/
>
>
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Herbert B. Chermside, CRA
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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